On April 9, 2020, the CFTC published revisions to its 2016 rules establishing the schedule for compliance with initial margin requirements applicable to swaps that are not cleared through regulated clearing houses. Under the revised rule, swap dealers, major swap participants, and other covered counterparties with between $8 billion and $50 billion in average daily aggregate notional amounts of uncleared swaps and other financial products will not be required to comply with the CFTC’s previously issued initial margin requirements for uncleared swaps until September 1, 2021, instead of the previous deadline of September 1, 2020.